PA Supreme Court: Rule 600 Speedy Trial Motion Not Always Waived by Defendant’s Bench Warrant

Philadelphia Criminal Defense Lawyer Zak T. Goldstein, Esq.

The Pennsylvania Supreme Court has decided the case of Commonwealth v. Barbour, holding that a defendant does not waive the speedy trial protections of Rule 600 by failing to appear for court without cause after the 365-day period for bringing a defendant to trial has already expired. Barbour is the second recent pro-defense decision from the Pennsylvania Supreme Court in recent months, suggesting that the Court has finally recognized that recent decisions of the Superior Court had completely eviscerated the rule’s protections and allowed defendants to languish in prison for years without trials through no fault of their own. 

The Issues in Commonwealth v. Barbour

The issue in Barbour was whether a defendant’s unexcused failure to appear for court waives the protections of Rule 600 even where the defendant’s 600 rights were already violated prior to the date on which the defendant failed to appear. As a general rule, Rule 600 of the Pennsylvania Rules of Criminal Procedure requires the Commonwealth to bring a criminal defendant to trial within 365 days of the filing of the complaint. If the Commonwealth fails to bring the defendant to trial within that time period, then the case should be dismissed with prejudice, meaning the Commonwealth cannot re-file the charges. 

In theory, the rule seems simple. In practice, it is much more complicated for a number of reasons. First, time between court dates for which the defendant is responsible for the delay do not count towards the 365-day calculation. This means that if the defendant requests a continuance of a hearing, then the time until the next hearing does not count for Rule 600 purposes.

Second, over the years, the Superior Court has created all sorts of absurd exceptions for why time does not count against the Commonwealth even when it’s the Commonwealth’s fault that that the case was continued. For example, trial courts routinely fail to count time during which the prosecutor was “duly diligent” but nonetheless could not proceed to trial on a given date. These types of continuances which do not count against the Commonwealth could include periods of time during which the defendant was not brought to court from custody or police officers were sick or injured on duty, or even where the prosecution simply needed more time to investigate the case and prepare for trial. Additionally, where the prosecution is ready to proceed but the trial judge is busy hearing a different case, the time will often be excluded from the Rule 600 calculation. 

Recent years have shown a marked trend of appellate courts forgiving every possible delay because of the reluctance to dismiss serious criminal charges based on what many would view as a technicality. However, the failure to protect a defendant’s right to a speedy trial has real costs to both the defense and the prosecution. When a defendant remains in jail waiting for trial for a year or more, the defendant could lose his or her job, home, and contact with his or her family all while presumed innocent.

Likewise, the prosecution’s case generally does not get better with age; witnesses may move out of the jurisdiction or forget key details about the incident, police officers may retire or get indicted, and prosecutors and detectives may lose evidence. Thus, Rule 600 really protects both sides. It protects the accused, who should not have to deal with the threat of criminal charges or pre-trial incarceration for lengthy periods of time, and it protects the prosecution, who benefits from proceeding to trial in a reasonably prompt manner. After years of decisions excusing endless delay from the courts and prosecutors, the Pennsylvania Supreme Court has finally begun to enforce the protections of Rule 600. 

In the prior cases of Commonwealth v. Steltz and Commonwealth v. Brock, the Supreme Court held that a defendant forever waives the protections of 600 by failing to appear for court as required. The rationale behind those decisions was that if a defendant fails to appear and obtains a bench warrant, then the defendant may then be brought to trial at the prosecution’s convenience.

In this case, the defendant obtained a bench warrant for failure to appear back in 2004. In 2014, the defendant was arrested on the bench warrant, and the court scheduled a new trial date. Prior to trial, the defendant moved to dismiss the charges pursuant to Rule 600. The defendant argued that this case was different from Steltzand Brock because in those cases, the defendants bench warranted prior to the expiration of the 365-day period. Here, however, the defendant’s bench warrant was issued after the Commonwealth had already failed to bring him to trial within 365 days. Thus, the defendant argued that he should not be able to waive Rule 600 where the Commonwealth had already violated the rule. 

Ultimately, the Supreme Court agreed. It re-affirmed the rule of Brock and Steltz that a bench warrant prior to the expiration of the 365-day period waives Rule 600, but it also held that where the Commonwealth has already violated Rule 600 prior to the bench warrant, the defendant’s unexcused absence at trial does not waive the protections of the rule. This is a good, but narrow, decision which will make the waiver doctrine of Steltz and Brock slightly less punishing for those who have already had their rights violated. 

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SCOTUS: Defendant May Waive Double Jeopardy by Moving to Sever Felon in Possession of Firearm Charge

Philadelphia Criminal Defense Lawyer Zak Goldstein

The United States Supreme Court has decided the case of Currier v. Virginia, holding that a defendant may waive double jeopardy protections by consenting to the severance of criminal charges and moving for separate trials on different charges. Specifically, the defendant may waive his or her double jeopardy rights by moving to sever a felon in possession of a firearm charge from the other charges in a criminal case. 

The Facts of Currier v. Virginia

In Currier, prosecutors charged the defendant with burglary, grand larceny, and unlawful possession of a firearm by a convicted felon in Virginia. Coincidentally, the defendant was not eligible to possess a gun because he had prior convictions for burglary and grand larceny. Because the defendant was charged with unlawful possession of a firearm by a convicted felon, prosecutors would have been allowed to introduce his prior convictions for burglary and grand larceny in his trial as the existence of those prior convictions is an element of the statute. This would have been detrimental to his case because the jury would have heard both that he had prior convictions in general and that he had prior convictions for the exact same thing with which he was charged. 

Accordingly, the defendant and the Government agreed to sever the charges and hold two separate trials. As discussed in the Court’s opinion, there is no universal way to handle this issue and each jurisdiction is different. In Virginia, a defendant can have two trials: one for the unlawful possession of a firearm by a convicted felon and a second trial for the other charges. In this case, Petitioner elected to have two trials. This is not the normal procedure in Philadelphia. In Philadelphia, the prosecutors will ordinarily proceed against the defendant on the non-felon in possession charges first. If the prosecution obtains a conviction on all of the charges other than the felon in possession charge, then the defense will typically allow the trial judge to make the decision on the remaining gun charge. If the jury acquits on all of the other charges, then the prosecution will usually move to nolle prosse the remaining gun charge. In some cases, the prosecution does still insist that the jury hear the felon in possession case after it has ruled on the other charges. However, Philadelphia does not typically conduct two separate trials in these types of cases. 

The first trial, for the charges of grand larceny and burglary, went very well for the defendant. He was acquitted of both charges. When he appeared for his second trial, his defense attorneys moved to dismiss the gun charge. They argued that it would violate his constitutional right against Double Jeopardy. In the alternative, he asked that the prosecution not be allowed to introduce any evidence pertaining to the grand larceny and burglary charges because he was acquitted of those charges. The trial court denied the defense's request, and the jury found him guilty of the gun charge. The court sentenced him to a lengthy period of incarceration. He appealed through the Virginia state appellate system, and both the Virginia Court of Appeals and the Virginia Supreme Court affirmed the denial of his double jeopardy motion. He appealed to the United States Supreme Court, and the Supreme Court granted certiorari and agreed to hear the case. 

What is Double Jeopardy? 

The Fifth Amendment of the United States Constitution prohibits a defendant from being tried twice for the same crime after he or she has been acquitted or convicted of the crime. These situations can become more complicated than one would expect, but a simple example of double jeopardy is this: Imagine a defendant is charged with robbing a bank. The defendant goes to trial, and the jury acquits him of robbing the bank. The same jurisdiction cannot then re-try him again for robbing the bank, even if prosecutors later uncover more evidence that would have likely led to a different verdict. 

It is important to note that under the federal constitution and subsequent case law, this protection only applies to the particular jurisdiction that tried the defendant. In other words, just because a defendant is acquitted of a crime at the federal level does not mean that the state government cannot prosecute for the crime too. However, the rules governing this depend on the jurisdiction. Pennsylvania offers much broader Double Jeopardy protections in comparison to other states. Thus, if a defendant is acquitted in federal court, Pennsylvania prosecutors cannot then bring charges. The reverse, however, is not true - if a defendant is acquitted in Pennsylvania court, the federal government can still bring charges. Click here to learn more about double jeopardy in general. 

The Double Jeopardy Clause also has a collateral estoppel component to it. What this means is that the government cannot re-litigate a fact that was decided in a defendant’s favor. To give a basic example of this, let’s assume that a defendant punched a person in the face and took their phone. This is technically a robbery, but it is also a simple assault. Let’s also assume that at trial, the government chooses only to proceed on the robbery charge and the defendant is found not guilty. The doctrine of collateral estoppel prevents the government from re-arresting the defendant for simple assault because he was already found not guilty of an essential fact of the case (i.e. punching the complainant) in the robbery trial. 

This idea of collateral estoppel, as discussed in Currier, is not a universally accepted idea by legal jurists and remains controversial. However, as the justices noted in their opinion, collateral estoppel was not the issue in this case, though it is a little confusing (as discussed below). The issue in Currier, according to the justices, was whether a defendant can waive his Double Jeopardy protections by seeking a severance of the charges filed against him. 

The Court Holds that a Defendant Can Waive His Double Jeopardy Protections When He Agrees to Severance of the Charges

In Currier, the Supreme Court held that a defendant may waive his Double Jeopardy protections when he elects to have two trials. In making its decision, the Court looked at its prior decisions that addressed the issue. In its research, the Court concluded that when a defendant elects to have two trials, he is no longer entitled to Double Jeopardy protections. The Court stated that the Double Jeopardy Clause was designed to protect against government oppression, not from the consequences of a defendant’s voluntary choice. 

The defendant, of course, argued that he had no real choice. If he had not elected to sever his cases, than the jury would have heard that he had prior convictions for the same offenses, and he would not have received a fair trial. However, the Supreme Court noted that though he was entitled to have separate trials under Virginia law, it was not a constitutional right to have separate trials. Thus, he was not forced to give up one constitutional right to secure another. Additionally, the Court held that because the defendant consented to the severance of the cases, the prosecution could still introduce evidence relating to the charges for which he had already been acquitted.

This decision will likely prove confusing and frustrating for criminal defendants because even though the defendant was found not guilty of the burglary and the grand larceny charges, the prosecution was allowed to introduce evidence for those crimes in his second trial. The Court made clear that its decision was based on the text of the Fifth Amendment and therefore held that the Double Jeopardy Clause only prohibits re-litigating offenses, not issues or evidence. Consequently, the Court held that the normal rules of evidence apply and thus a trial court must decide whether to allow the introduction of evidence and facts from the prior trial. 

Facing criminal charges? We can help.

Criminal Defense Attorneys Zak Goldstein and Demetra Mehta

If you are facing criminal charges in state or federal court, we can help. Our award-winning Philadelphia criminal defense lawyers have successfully defended thousands of criminal cases in trial and appellate courts throughout Pennsylvania and New Jersey. If you are under investigation or have been arrested, we offer a 15-minute criminal defense strategy session free of charge. Call 267-225-2545 to discuss your case with an experienced and understanding criminal defense attorney today. 

PA Superior Court: Commonwealth Cannot Appeal Dismissal for Lack of Evidence at Preliminary Hearing, Must Re-File Instead

Commonwealth v. Perez

Philadelphia Criminal Defense Lawyer Zak Goldstein

The Pennsylvania Superior Court has decided the case of Commonwealth v. Perez, holding that the Commonwealth may not file an interlocutory appeal following the dismissal of charges for lack of evidence at a preliminary hearing. The court held that the Commonwealth must instead re-file the charges and ask that a different magistrate hear the case.

The Facts of Commonwealth v. Perez

In Perez, the defendant was charged with first-degree Murder and Possession of an Instrument of Crime (“PIC”). The Commonwealth filed the charges against the defendant in the Philadelphia Municipal Court, and the case was scheduled for a preliminary hearing before a Municipal Court judge. At the conclusion of the hearing, the MC judge dismissed the charges, finding that the Commonwealth failed to establish a prima facie case of Murder or PIC at the preliminary hearing.

The Commonwealth re-filed the charges. When the Commonwealth re-files on homicide charges in Philadelphia, the preliminary hearing takes place again before a judge in the Court of Common Pleas. When the Commonwealth re-files in the suburban counties, a different Magisterial District Justice, or sometimes even the same justice, will hear the case again. In this case, the Common Pleas homicide judge presided over the second preliminary hearing, and the Commonwealth presented additional evidence. Despite the fact that the Commonwealth presented additional evidence, the Common Pleas judge agreed that there was simply not enough evidence to find that the defendant committed the murder. The judge again dismissed the charges, and the Commonwealth appealed to the Superior Court.

Why would a case get dismissed at the preliminary hearing?

In a criminal trial before a judge or a jury, the Commonwealth must prove the defendant’s guilt beyond a reasonable doubt or the factfinder must acquit the defendant. The standard at a preliminary hearing, which typically occurs within the first few weeks or months of a case, is much lower. The Commonwealth must only show that a crime occurred and the defendant probably committed it. The Commonwealth is entitled to all reasonable inferences in its favor and in the suburban counties, may generally proceed entirely on hearsay presented by police officers. In Philadelphia, the Commonwealth generally cannot get away with proceeding entirely based on hearsay, but some hearsay is still allowed under the rules. If the Commonwealth fails to prove that it is more likely than not that the defendant committed the crime charged, then the court should dismiss the charge or reduce the gradation to the level that was proven by the prosecution.

Is the case over if it gets dismissed at a preliminary hearing?

There are two main reasons why a case would be dismissed at a preliminary hearing. First, if the prosecution is repeatedly not ready to proceed because witnesses have failed to appear, then the case could be dismissed for lack of prosecution (“DLOP”). In Philadelphia, this typically takes place when the Commonwealth is not ready to go three times in a row. Second, if the prosecution presents a case but the evidence fails to prove by a preponderance of the evidence (51%) that the defendant committed the crimes charged, then the judge should dismiss the charges for lack of evidence (“DLOE”). Both types of dismissals are not necessarily the end of the case because the Commonwealth may re-file the charges. When the Commonwealth re-files the charges, the preliminary hearing will be heard again by a different judge. In Philadelphia, re-filed cases stemming from dismissal for lack of evidence are heard either in Motions court by a Common Pleas judge if it is a non-homicide case or by one of the homicide judges in a murder case. The Common Pleas judge will review the notes of testimony from the preliminary hearing and receive any additional evidence which the parties wish to present. In the suburban counties, a Magisterial District Justice will conduct an entirely new preliminary hearing.  

Are there limits on the Commonwealth’s ability to re-file after a dismissal at the preliminary hearing?

Although the Commonwealth may re-file the charges following a dismissal for lack of evidence, the Commonwealth’s ability to re-file is not unlimited. Pennsylvania appellate courts have held that where the charges are repeatedly dismissed by the preliminary hearing magistrates, the successive re-filing of the charges could eventually reach the point of prosecutorial harassment and implicate due process rights. In that case, the charges could be dismissed without prejudice or the trial judge could prohibit the Commonwealth from re-filing the charges. The Commonwealth would then be limited to appealing the case to the Superior Court and asking the Superior Court to find that the evidence presented was sufficient to show that defendant probably committed the crime.

The Criminal Appeal in Perez

In Perez, the Commonwealth re-filed the charges once with the homicide judge in the Court of Common Pleas, and that judge still dismissed the murder charge without prejudice. Instead of attempting to re-file again before a different judge, the Commonwealth filed a motion to reconsider the dismissal order and eventually appealed the case to the Superior Court when that motion to reconsider was denied.

The Superior Court rejected the appeal, however, and refused to reach the merits of the case. The court found that the Commonwealth could not appeal the trial court’s decision because the order dismissing the charges was not a final order. In general, Pennsylvania appellate courts only have jurisdiction over appeals of final orders. A final order is one that disposes of all of the parties and all of the claims, meaning no further action is pending in the trial court. However, when a trial court dismisses criminal charges at a preliminary hearing, the Commonwealth can simply re-file the charges (assuming that they have not re-filed so many times that it would constitute prosecutorial harassment). Therefore, the Superior Court found that the appeal from the dismissal order was interlocutory and premature. The court denied the appeal, finding that the Commonwealth should have simply re-filed instead. Had the dismissal of the charges been with prejudice, meaning that the Commonwealth could not re-file, then the appeal would have been proper. Thus, Perez clearly establishes that the Commonwealth must re-file until no longer allowed before taking an appeal to the Superior Court.

The Impact of Perez

The Superior Court’s decision is somewhat counter-intuitive, but there are still protections for a defendant who is facing criminal charges. First, if more than one judge dismisses the charges, the Commonwealth may decide that they simply do not have a case and give up instead of continuing to re-file the charges. Second, Pennsylvania appellate courts have held that the Commonwealth’s ability to re-file is not limitless. Although there is no set number of times that the Commonwealth may re-file, the courts have found that “[I]f the Commonwealth’s conduct intrudes unreasonably upon the due process right of individuals to be free from governmental coercion, the Commonwealth should not be permitted to present the case repeatedly before successive magistrates.” In practice, this usually means that if the Commonwealth re-files more than once and the case is dismissed two or three times, the courts will likely dismiss the charges with prejudice and prevent the Commonwealth from re-filing. In that case, the Commonwealth could appeal the dismissal of the criminal charges to the Superior Court because that would be a final order. Likewise, where a trial judge in the Court of Common Pleas grants a Motion to Quash (also called a Petition for Writ of Habeas Corpus in the suburban counties), the Commonwealth may appeal that ruling to the Superior Court because the Commonwealth is prohibited from simply re-filing in order to evade the Common Pleas judge’s decision quashing the charges.

It is hard to say whether the court’s opinion in Perez benefits the Commonwealth or the defense. In general, allowing the Commonwealth to repeatedly re-file charges can be extremely expensive and stressful for a defendant as the defendant has to repeatedly defend against the charges at successive preliminary hearings. It also allows the Commonwealth to keep trying until the Commonwealth gets a judge that will rubber stamp the charges. At the same time, defending an appeal to the Superior Court is far more complicated, time-consuming and expensive than defending a preliminary hearing. Superior Court appeals can also take years. Therefore, criminal defendants may benefit in terms of cost and obtaining a resolution more quickly as this decision requires the Commonwealth to proceed by re-filing until prohibited by court order from doing so.

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Philadelphia Criminal Defense Lawyers

If you are facing criminal charges or under investigation, we can help. Our award-winning Philadelphia criminal defense lawyers have successfully defended thousands of clients in state and federal courts throughout Pennsylvania and New Jersey. We are experienced and understanding defense attorenys who will fight for you. We offer a free 15-minute criminal defense strategy session to each potential client. Call or text 267-225-2545 to speak with an attorney today. 

PA Supreme Court Finds Autopsy Reports Testimonial under Confrontation Clause

Philadelphia Criminal Defense Attorney Zak Goldstein

The Pennsylvania Supreme Court has decided the case of Commonwealth v. Brown, holding that autopsy reports are testimonial and therefore may not be introduced at trial unless the witness who prepared the report testifies. In this case, however, the court found that the improper admission of the  autopsy report was harmless error, so the defendant did not receive a new trial.

The Facts of Commonwealth v. Brown

In Brown, the defendant attended a party on Stanley Street in Philadelphia. Before arriving at the party, he hid a gun in the wheel well of a nearby parked car. The defendant argued with someone during the party, and his co-defendant then retrieved the gun from the car and gave it to the defendant. The defendant shot the person with whom he was arguing four times, killing him. A doctor with the Philadelphia Medical Examiner’s Office performed an autopsy and prepared a report of the findings. The report found that the decedent had been shot four times, the shots struck the ribs, heart, lungs, and shoulder of the victim, and three of the bullets entered the front of the victim’s body while one entered his back. The report also described the trajectory of the bullets in the victim’s body and noted that there was no soot, stippling, or muzzle imprints around any of the gunshot wounds. The report noted that the cause of death was multiple gunshot wounds and the manner of death was homicide.

At the time of trial, the doctor who performed the report no longer worked for the city. The Commonwealth did not call him to testify at the trial. Instead, the Commonwealth admitted the report into evidence by calling a different doctor who had reviewed the report to testify to the other doctor’s report. The defendants objected, arguing that the admission of the report without the testimony of the doctor who prepared it violated the Confrontation Clause of the Sixth Amendment of the United States. Based on the other doctor’s report, the testifying doctor told the jury that the wounds were consistent with a scenario in which someone shot the victim from a distance of six to eight feet away while facing him, and then shot the victim in the back after the victim turned away. He further testified that the victim could have walked a few feet before collapsing.

The jury convicted the defendant of third-degree murder and related offenses, and the court sentenced him to 25 – 50 years in prison. The defendant appealed, and the Superior Court affirmed his conviction. The court first ruled that the report should not have been admitted, but it found harmless error because there was no real dispute about the cause of death.

The Criminal Appeal

The defendants again appealed to the Pennsylvania Supreme Court, and the Supreme Court agreed to review the case. On appeal, the Commonwealth argued that autopsy reports are not testimonial because they are not necessarily created for trial in the same way that a BAC report or drug test report is prepared specifically for trial. Instead, state law requires coroners to prepare autopsy reports regardless of whether there is an ongoing criminal activity. The defendant argued that although some autopsy reports are prepared regardless of whether there is a suspicion of criminal activity, the law requires the coroner to prepare a report in response to any suspicious death and cooperate with the prosecutor. Further, the report in this case was prepared for the prosecution of homicide charges.

What is the Confrontation Clause?

The Pennsylvania Supreme Court agreed with the Superior Court that the report was testimonial and therefore should not have been admitted without the testimony of the doctor who prepared it. The Confrontation Clause, which is part of the Sixth Amendment, provides criminal defendants with the right to confront the witnesses against them. This means that they have the right to cross-examine witnesses under oath at trial.

The Pennsylvania Supreme Court noted that in Crawford v. Washington, the United States Supreme Court created the modern analysis of the Confrontation Clause. The Court barred the admission of testimonial statements of a witness who did not appear at trial unless the witness is unavailable and the defendant has had a prior opportunity to cross-examine the witness. Thus, the key question for whether a statement violates the Confrontation Clause is whether the statement is testimonial. In general, statements are testimonial when their primary purpose is to establish or prove past events for purposes of proof at a criminal trial. This means that statements made to police officers who are investigating cases are typically going to be testimonial. Likewise, lab reports prepared to prosecute a criminal defendant at trial will also generally be found to be testimonial. On the other hand, statements which are not made for the purposes of criminal prosecution – such as a phone call to 911 in order to obtain emergency assistance – will often be found non-testimonial.

The Court's Decision

Ultimately, the Court concluded that the autopsy report was testimonial. Pennsylvania law requires the preparation of autopsy reports in all cases of sudden, violent, and suspicious deaths, or deaths by other than natural causes, and in such cases, the autopsy and subsequent report are designed to determine whether the death occurred as the result of a criminal act. The law also requires the coroner to advise and cooperate with the District Attorney. Therefore, the primary purpose of an autopsy report is to establish or prove past events potentially relevant to a later criminal prosecution. Any person creating the report would reasonably believe it would be available for use at a later criminal trial. Therefore, an autopsy report is testimonial. 

What is Harmless Error?

At the same time, the Supreme Court concluded that the defendant was not entitled to a new trial because the admission of the report amounted to harmless error. Even where the trial court has made a mistake in an evidentiary ruling, an appellate court may find harmless error where 1) the error did not prejudice the defendant or the prejudice was de minimis, 2) the erroneously admitted evidence was merely cumulative of other untainted evidence which was substantially similar to the erroneously admitted evidence, or 3) the property admitted and un-contradicted evidence of guilt was so overwhelming and the prejudicial effect of the error was so insignificant by comparison that the error could not have contributed to the verdict.

Here, the Court found that the error was harmless error because the report was merely cumulative to the properly admitted testimony of the testifying doctor relating to the cause of death. Specifically, it was harmless error because the doctor had reached his own independent opinion regarding the cause of death which did not rely entirely on the inadmissible autopsy report. Further, an expert witness generally may rely on inadmissible evidence if it is the type of evidence that an expert in the field would normally rely on in reaching a determination. Thus, the report itself should not have been admitted, but the doctor was properly permitted to rely on it in reaching his own conclusions. Therefore, the defendant was not entitled to a new trial. 

Facing Criminal Charges? We Can Help.

Philadelphia Criminal Defense Attorneys

If you are facing criminal charges or may be under investigation by law enforcement, we can help. Our Philadelphia criminal defense attorneys have successfully defended thousands of clients in Pennsylvania and New Jersey. We offer a free 15-criminal defense strategy session to each potential client, and we can help you build a defense to pending criminal charges or evaluate the merits of filing a PCRA or direct appeal. Call 267-225-2545 to speak with an experienced and understanding criminal defense lawyer today.